The latest notice from HUD regarding EIV, Notice 2011-21, states that the No Income Report has to be run for “ALL” recertification months.
Obviously, the people who write the program and the people who write the regulations don’t always understand each other…this report appears to be meant to be run at the time of annual recertification to confirm whether or not a resident has zero income reported to EIV. As we know that this report does not mean that a resident has ZERO INCOME it is not as useful as HUD would have us think.
However, we live in a “do as your told” world (especially dealing with HUD and its regulations), so you are required to run the No Income Report on “ALL” recertification months as described in your policies and procedures. It is important to develop a standard policy about when this report will be run and what you will be required to do with the results. If you are running the report at a time not included in your P&P you will also run into trouble!
Even though it seems counterproductive, make sure this becomes part of your procedures!
Happy verifying!